Privacy Policy

Introduction

This is the Privacy Policy for Dante Management Limited, a company registered in England and Wales (company number 15040220) whose registered address is 2nd Floor, Curzon House, 24 High Street, Banstead, Surrey, England, SM7 2LJ. (“Dante”). This Privacy Policy applies to your use of our website at www.dantetalent.com.

Dante (and its affiliated companies and brands) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.


1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Dante collects and processes your personal data through your use of this website, including any data you may provide through this websiteThis privacy policy aims to give you information on how Dante collects and processes your personal data through your use of this website, including any data you may provide through this website
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Dante is the controller and responsible for this website. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: Dante Management Limited

Email address: data@dantetalent.com

Postal address: 2nd Floor, Curzon House, 24 High Street, Banstead, Surrey, SM7 2LJ

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Through the website, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • create an account on our website;
  • subscribe to our services or publications;
  •  request marketing to be sent to you;
  •  enter a competition, promotion or survey; or
  • give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below [TO BE CONFIRMED]:

  • Technical Data from the following parties
    • analytics providers such as Google based outside the UK;
    • advertising networks (both in and outside the UK); and
    • search information providers (both in and outside the UK).
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services
  • Identity and Contact Data from publicly available sources

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform the contract we are about to enter into or have entered into with you;
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interest; and
  • where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest

To register you as a new client and verify your identity (where required) and to provide you and your child with our services

 a) Identity
(b) Contact
(c) Financial
(d) Special category data

Performance of a contract with you and provision of services to you and your child

 

Consent (for use of special categories of data)

To process and deliver services to you and your child including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

 (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(f) Special category data		 (a) Performance of a services contract with you and your child
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey		 (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications		 (a) Performance of a services contract with you and your child
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our services)

To respond to queries and enquiries

 (a) Identity
(b) Contact		 Legitimate interests

To undertake marketing to you

 (a) Identity
(b) Contact
(c) Marketing and Communications

Consent, unless our legitimate interests apply and this does not adversely affect your rights as a data subject
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage		 Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications		 Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or worked with us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can opt-out of receiving marketing communications from us at any time by contacting us via the following methods.

1. Email us at data@dantetalent.com providing your full name, address and postcode and the email address which you would have originally used.
2 .Write to Dante Talent at 2nd Floor, Curzon House, 24 High Street, Banstead, Surrey, SM7 2LJ
4. You can also be removed from our email database by clicking the Unsubscribe link located in the footer of all marketing email communications from Us.
5. You can update your preferences by sending an email to data@dantetalent.com.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see COOKIE POLICY.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

Where we act as the data controller, personal data processed by Dante may be shared as follows:

  • with any member of the Dante group of companies, which means Dante Management Limited’s subsidiaries, Dante’s ultimate holding company (currently Dante Group Limited) and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
  •  where Dante is under a duty to disclose your personal data (or that of your child) to comply with any legal obligation, or to enforce or apply Dante’s terms and conditions and other agreements;
  •  to protect the rights, property, or safety of Dante, Dante’s client, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and for compliance with laws;
  • with the authorities, Foreign and Commonwealth Office or other regulatory or official purpose, as may be appropriate for regulatory purposes; and
  •  with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

Third party service providers

To fulfil our services contracts, appropriate personal data will be passed on to the relevant third party supplier / any other third party (including banks and/or credit card issuers) who need to process your

and your child’s personal data so that services can be provided. The information may also be provided to government / public authorities if required by them, or as required by law.

We only provide third parties with the personal data they require in order to deliver their services and fulfil a specific service on your behalf, and their use is limited to the services they provide.

We require all third parties to respect the security of your and your child’s personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your or your child’s personal data for their own purposes and only permit them to process your or your child’s personal data for specified purposes and in accordance with our instructions.

Certain of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your or your child’s personal data to countries outside of the EEA to other people or companies it will be for one of the legal bases for processing your or your child’s personal data as indicated above.  Where we do so, we will take all steps to ensure that any country to which the personal data has been transferred has suitable protection mechanisms in place to protect personal data, including (if applicable) use of standard contractual clauses for making international data transfers in any contract with that third party for steps to be taken to keep personal data secure.  We will always ensure suitable safeguards are implemented.

Please contact us if you want further information on the specific mechanism used by us when transferring your or your child’s personal data out of the UK.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to you or your child’s personal data. These include the right to: 

  •  The right to be informed – this is information on for what purpose we are processing it and what personal data we are processing.
  •  The right of access (commonly known as a “subject access request”) – you have the right to be provided with copies of the personal data of you (or your child) that We are processing as well as confirmation of the processing we are doing. You can do this by sending a “subject access request” to the contact details noted above for Our consideration.
  •  The right to rectification – if you think the personal data that we hold on you or your child is wrong you can tell us and we will fix it, though we may need to verify the accuracy of the new data you provide to us.
  •  The right to erasure (also known as the right to be forgotten) – if you want us to permanently delete the personal data we hold for you or your child then you can ask us to do so. This also enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • The right to restrict processing – you have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  •  The right to data portability – if you want us to pass on your or your child’s personal data to someone else then please let us know. This transfer should not affect the integrity or otherwise damage your or your child’s personal data.
  • The right to withdraw your consent – you can withdraw your consent for us to process your or your child’s personal data (if we have relied on your consent to process your or your child’s personal data) at any time by contacting us. If we have relied only on your consent as the basis to process your or your child’s personal data then we will stop processing your or your child’s personal data at the point you withdraw your consent. Please note that if we can also rely on other bases to process your or your child’s personal data aside from consent then we may do so even if you have withdrawn your consent.
  • Rights in relation to automated decision making and profiling – if we use either automated decision making or profiling then you have a right to know. Also, we need your consent if either of these are used to make a decision that affects you. As with all consent, you can withdraw it at any time.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated

Children

The Website is not intended for children and Dante will not knowingly collect any personal data from persons under the age of 18 directly.  Where, as part of the Services being provided we may collect information about children from you to perform such Services and we will treat such information securely and in line with this Privacy Policy.

Complaints

If you would like to make a complaint in relation to how Dante may have stored, used or processed your personal data, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). Dante would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

The Website may, from time to time, contain links to and from the websites of Dante partner networks, advertisers and affiliates, as well as other sites owned within the Dante Group. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Dante is not responsible for the content of external internet sites and you are advised to read the privacy policy of external sites before disclosing any personal data.

Remember the Risks Whenever You Use the Internet

Dante is committed to ensuring that your information is secure and has in place reasonable and proportionate safeguards and procedures to protect your personal data. Whilst Dante does its best to protect your personal data, Dante cannot guarantee the security of any information that you transmit to Dante and you are solely responsible for maintaining the secrecy of any passwords or other account information.

Changes to this Privacy Policy and your duty to inform us of changes

As and when necessary, changes to this Privacy Policy will be posted here. Where changes are significant, we may also email all our registered users with the new details, and where required by law, we will obtain your consent to these changes.

Published and last updated 1 October 2023